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Following the passage of the Tax Reform Act of 1969 (1969
Act), Pub. L. 91-172, sec. 951, 83 Stat. 730, the United States
Tax Court is the functional equivalent of a District Court. See
sec. 951 of the 1969 Act, 83 Stat. 730. See also Freytag v.
Commissioner, 501 U.S. 868, 890-891 (1991). Through the 1969
Act, Congress changed the status of this Court from an
"independent agency in the Executive Branch of the Government" to
a "court of record" "established * * * under Article I of the
Constitution of the United States". See sec. 7441 before and
after amendment by the 1969 Act; see also Freytag v.
Commissioner, supra at 890-891. Congress established the United
States Tax Court through a constitutionally permissible exercise
of its Article I powers. See Freytag v. Commissioner, supra.
The United States Tax Court, as established by Congress under the
1969 Act, sits as a District Courtlike tribunal that "exercises a
portion of the judicial power of the United States * * *. * * *
to the exclusion of any other function". Id. at 891. This
Court's judicial power allows the Court to decide cases without
undue influence from either the executive or legislative branch.
See id. at 890-891; Roberts v. Commissioner, 175 F.3d 889 (11th
Cir. 1999); see also Burns, Stix Friedman & Co. v. Commissioner,
57 T.C. 392, 395 (1971), wherein the Court stated:
It is clear from the statutory language and the Senate
committee report (S. Rept. No. 91-552, 91st Cong., 1st
Sess., p. 302, 1969-3 C.B. 614) that Congress removed
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